Bilbray was a member of the class of 1994 who lost his old House seat in 2000, then stayed in Washington as a lobbyist for the Federation for American Immigration Reform, which advocates "a temporary moratorium on all immigration except spouses and minor children of U.S. citizens and a limited number of refugees." Bilbray returned to Congress in a 2006 special election, which he won in part by accusing his Democratic opponent of soliciting votes from illegal aliens. Since then, Bilbray has maintained a 92% rating from the American Conservative Union, which makes him an "ACU Conservative" in their ranking system. He voted against increasing the minimum wage, voted to repeal the Washington, D.C. gun ban, voted against a ban on anti-gay job discrimination, and voted against expanding SCHIP.

Voting against a minimum wage increase, expanding health insurance for kids, and against banning workplace discrimination puts Bilbray far out of the mainstream of the American people. And in the last Congress, Bilbray's voting record put him far to the right of most of his colleagues, too -- he was the 79th most conservative member of the House of Representatives, out of a total of 435. That means Bilbray's voting record was more conservative than more than 80 percent of all members of Congress.

To Politico, that makes him a "centrist." Just like MSNBC's Norah O'Donnell thinks Diane Feinstein is one of the "most liberal" Senators. And Time's Jay Newton-Small thinks Lindsey Graham is a "moderate."